Content uploaded by Serkan Girgin
Author content
All content in this area was uploaded by Serkan Girgin on Jan 23, 2018
Content may be subject to copyright.
TOWARDS AN ALL-HAZARDS APPROACH TO EMERGENC Y PREPAREDNESS AND RESPONSE, NEA No. 7308, © OECD 20 18 61
Chapter 4. Emergency planning and response for Natech accidents
by Amos Necci, Elisabeth Krausmann and Serkan Girgin1
Introduction
Natural hazards, such as earthquakes, floods, storms, extreme temperatures, etc., can
trigger fires, explosions and toxic or radioactive releases at hazardous installations and
other infrastructures that process, store or transport dangerous substances. These
technological secondary effects of natural hazard impacts are also called “Natech”
accidents (from “natural hazard-triggered technological accident”). Natech accidents are
frequent in the wake of natural disasters, and they have repeatedly had significant and
long-term social, environmental and economic impacts (e.g. Krausmann and Cruz, 2013;
Girgin, 2011; Krausmann, Cruz and Affeltranger, 2011; Godoy, 2007). It should be noted that
Natech accidents can be triggered by any kind of natural hazard; a major natural hazard,
like a strong earthquake or a hurricane, is not necessarily required to cause a Natech event.
Recent studies highlighted that the specific aspects of Natech risk are unfortunately
often overlooked in chemical accident prevention programmes and disaster risk
reduction frameworks, causing Natech accidents to recur (Krausmann and Baranzini,
2012). This is compounded by the predicted increase of Natech risk as a result of
worldwide industrialisation, climate change, population growth and community
encroachment on natural hazard zones. This outlook has triggered initiatives that aim to
close gaps in Natech risk reduction. For instance, the OECD Working Group on Chemical
Accidents has recently produced a Natech Addendum to the OECD Guiding Principles on
Chemical Accident Prevention, Preparedness and Response (OECD, 2015).
This chapter will introduce the problem of Natech risks with a focus on emergency
planning and response. It will present major lessons learnt that were obtained from an
in-depth analysis of Natech accidents in the European Commission’s eNatech accident
database (http://enatech.jrc.ec.europa.eu) and make recommendations on how to close
remaining gaps. A comprehensive treatment of Natech risks and how to manage them is
available in Krausmann, Cruz and Salzano (2017).
This chapter is an original contribution to the EGNE report and has not been
published in this form elsewhere. It reflects the authors’ experience in this field, with
supporting information from the references listed at the end of the chapter.
Challenges for emergency planning and response for Natech accidents
The extent and consequences of Natech accidents have often reached major proportions
which is indicative of low preparedness levels. There is no single determining factor to
explain this, but the reasons are manifold, the main problem being that the
characteristics of Natech events differ significantly from those of conventional
technological accidents both in terms of prevention and mitigation. Successfully
1. Amos Necci, Elisabeth Krausmann and Serkan Girgin are from the European Commission’s Joint
Research Centre in Ispra, Italy.
EMERGENCY PLANNING AND RESPONSE FOR NATECH ACCIDENTS
62 TOWARDS AN ALL-HAZARDS APPROACH TO EMERG ENCY PREPAREDNESS AND R ESPONSE, NEA No. 7308, © OECD 20 18
controlling a Natech accident has often turned out to be a major challenge, if not
impossible, in cases where no prior preparedness planning has taken place. For instance,
when a natural hazard impacts a hazardous installation, it can trigger simultaneous
hazardous materials releases from multiple sources over extended areas within a very
short time frame. This poses a severe strain on emergency responders who are usually
neither trained nor equipped to handle a high number of substance releases at the same
time. For instance, the 1999 Kocaeli earthquake in Turkey triggered fires simultaneously
in three different parts of a major refinery. International assistance was necessary to
combat the fires and keep them from escalating (Girgin, 2011).
In situations of this kind, the risk of cascading disasters is high, especially in case of
flammable-substance releases. During the Tohoku earthquake and tsunami that hit
Japan in 2011, a large number of installations with major accident potential were
damaged or destroyed by the natural disaster impact which eventually caused a series of
hazardous materials releases and fires. The fires at the Chiba oil refinery involved
17 tanks storing liquefied petroleum gas (LPG) and resulted in at least five major
explosions, the biggest of which generated a fireball of over 600 m diameter and height
causing damage to nearby residential areas and assets (Krausmann and Cruz, 2013). Air
dispersion of flammable vapours from ruptured LPG pipes and subsequent ignition, heat
impingement from the burning LPG storage tank farm, as well as burning missile
projection triggered fires at two neighbouring chemical facilities.
Safety barriers aim to protect industrial equipment as well as people from the effects of
an accident. The barriers can be structural (e.g. containment dikes around tanks or vessels,
deluge systems, etc.) or organisational (e.g. communication, transportation routes for
evacuation, etc.). The natural event that causes damage at a hazardous installation will
likely also disrupt or destroy safety barriers on- and off-site. For example, the storm surge
that followed Hurricane Katrina in 2005 caused the spreading of oil from a spill at a refinery
in Meraux, which contaminated a large area with over 1 800 houses. The hydrocarbon
release triggered by the storm could not be contained, since the floodwaters had already
filled the bund around the damaged tank that was supposed to contain the release (US EPA,
2006). Another example is the impact of the 1999 Kocaeli earthquake in Turkey where some
6 500 tons of highly toxic acrylonitrile were released into containment dikes and to the
atmosphere. As a result of dike overflow and earthquake-triggered cracks at the bottom of
the concrete dikes, the substance was eventually also released into the sea and the
underground water aquifer. Many workers, first responders and residents of the nearby
settlements suffered from acute toxicity effects (Girgin, 2011). The evacuation order that
followed the toxic release forced a halt to the rescue activities and left people trapped under
the debris generated by the earthquake.
Another frequent issue is the disruption of lifelines needed for accident prevention or
mitigation during a natural event (e.g. power for keeping dangerous processes under
control or for shutting them down safely, water for firefighting or cooling). The Kocaeli
earthquake in Turkey not only triggered massive fires at a refinery in Körfez, it also
caused the loss of electric power on-site, as well as a shortage of water supplies that
resulted from damage to a main water pipeline. As a result, one of the fires burned out of
control and engulfed many other units until a conflagration forced the responders to
retreat (Girgin, 2011; Steinberg and Cruz, 2004). The accidents mentioned above highlight
that simultaneous emergency response efforts are required to cope with the impact of
the natural disaster on the population and the consequences of the Natech accident that
pose a secondary threat. Often, in such a situation there is competition for resources that
in the worst case might leave some urgently needed response mechanisms unavailable.
They also demonstrate how Natech accidents can hamper emergency response to natural
disaster victims when the released toxic, flammable or explosive substances endanger
the rescuers themselves. In this case first responders will have to evacuate, possibly
leaving people still trapped in buildings behind.
EMERGENCY PLANNING AND RESPONSE FOR NATECH ACCIDENTS
TOWARDS AN ALL-HAZARDS APPROACH TO EMERGENC Y PREPAREDNESS AND RESPONSE, NEA No. 7308, © OECD 20 18 63
Standard civil protection measures commonly used during conventional technological
accidents with substance releases, like shelter-in-place or evacuation, may not be
functional or appropriate in case of a Natech accident. The natural event that caused the
Natech accident in the first place could also have affected the structural integrity of the
housing in the proximity of the damaged installation, thereby rendering shelter-in-place
impossible. Similarly, access roads could have been washed away or be obstructed by
debris, hampering access to the site and, eventually, evacuation.
State of play in Natech emergency planning and response
“Natech emergency management” is the set of all actions that aim to prevent, prepare for,
respond to and recover from an emergency situation that has resulted from a Natech
accident. A good emergency plan should always be based on a risk assessment through
which potential emergency scenarios have been identified and their consequences
assessed. This emergency plan should be followed by first responders when an
emergency occurs.
Since the likelihood of an accident cannot ever be reduced to zero, the emergency
plan should include actions or systems that limit the consequences of an emergency. In
order to preserve the health and safety of people, property and the environment, as well
as to support short-term recovery, this plan should include both physical (e.g. tank bunds,
containment walls, levees and momentum breakers, firefighting equipment), and
organisational prevention and preparedness measures (e.g. land-use planning, training of
personnel), which are taken prior to the occurrence of the emergency.
Few countries have explicit provisions that require the operators of hazardous
installations to consider Natech risks in their safety documents for accident risk
assessment and management. Usually these requirements have been implemented in
the aftermath of one or several major Natech accidents. These rules require companies to
take any additional measures necessary to assess and to reduce the risk of accidents, to
protect its workers and the public from any accidental releases caused by natural hazards.
In the European Union, Directive 2012/18/EC on the control of major accident hazards
involving dangerous substances (Seveso III Directive) explicitly addresses Natech hazards.
The national governments are thus required to ensure that installations routinely
identify the natural hazards, such as floods and earthquakes, that could pose a risk to the
installations, and to evaluate this risk in safety reports. The inclusion of Natech risks in
the Seveso Directive acknowledges that awareness of this risk has been growing in
Europe since the Natech accidents that occurred during the 2002 summer floods.
Nevertheless, the level of concern about Natech events varies in EU member states.
As an example of Natech awareness, France passed a regulation (Decrees 210-1254
and 2010-1255, 2010) which introduced a new zoning for industrial installations in
seismic areas. In order to identify Natech risks and to facilitate emergency planning,
industrial establishments were split into two risk categories: “normal risk” and “special
risk”. Installations in the second category have to guarantee the containment of
hazardous materials under seismic loading by complying with specific mechanical
resistance requirements to ensure a structure’s capability to withstand a given value of
ground acceleration, chosen in accordance with the seismic zone (Planseisme, 2016).
Also, the German government passed a Technical Rule on Installation Safety 310 in
2012, according to which industrial establishments with major chemical accident
potential are required to assess the risk of flood-triggered accidents at their installations,
to take necessary risk reduction measures, and to consider the possibility of an increase
of flood risk due to climate change (TRAS 310, 2012a).
EMERGENCY PLANNING AND RESPONSE FOR NATECH ACCIDENTS
64 TOWARDS AN ALL-HAZARDS APPROACH TO EMERG ENCY PREPAREDNESS AND R ESPONSE, NEA No. 7308, © OECD 20 18
In the United States, the State of California released the Accidental Release
Prevention (CalARP) programme, which calls for a risk assessment of potential hazardous
materials releases due to an earthquake (CalARP, 2014). The purpose of the CalARP
programme is to prevent accidental releases of substances that can cause serious harm
to the public and the environment, to minimise the damage if releases do occur, and to
satisfy community right-to-know laws. Businesses that handle regulated hazardous
substances are required to develop a risk management plan which includes a detailed
analysis of the potential accident factors, together with the measures that can be
implemented for prevention and preparedness.
In Japan, the Law on the Prevention of Disasters in Petroleum Industrial Complexes
and Other Petroleum Facilities was updated after the Tokaichi-oki earthquake triggered
several fires at a refinery in 2003 (Cruz and Okada, 2008). Moreover, the Japanese
government has prepared the Large-Scale Earthquake Countermeasures Special Act,
introducing amendments in the Japanese High Pressure Gas Safety Law, which requires
companies to take any additional measure necessary for the protection of its workers and
the public from any accidental releases caused by earthquakes and tsunamis.
Lessons learnt from Natech accidents
During past Natech accidents, emergency responders were often caught unprepared by
the conjoint natural-technological disaster and some mitigation systems were either
non-functional (e.g. flooded containment dikes) or inoperable (e.g. damaged firefighting
systems). It is important to learn from past accidents to prevent the occurrence of the
very same dramatic outcomes in the future.
Many Natech accidents showed that it is not enough to prepare only for a recurrence
of events that have happened in the past. For instance, the catastrophic floods which
severely affected the Czech Republic in 2002 caused the failure of several chlorine tanks
after an industrial site was flooded with water exceeding by 1.3 m the 100-year water level
against which the installation was protected (Hudec and Lukš, 2004). Climate change has
started to affect the return period of many hydro-meteorological hazards, rendering
numerous hazardous facilities vulnerable to the more severe natural hazard effects.
The forensic analysis of numerous past Natech accidents indicated that during the
development of emergency plans the effect of natural disasters on the infrastructure in the
territory (e.g. utilities, electricity, roads, communication lines) and on the population
(e.g. non-feasibility of evacuation or sheltering in place, unavailability of internal or
external emergency response resources) was often not considered. This meant that no or
only few response measures were available to combat the consequences of a Natech
accident. For instance, the unavailability of firefighting systems was observed during many
earthquakes (Kocaeli, Tohoku) but also during other natural hazard events. A fire at a
storage site in France in winter 2012 could not be responded to by the fire department as
the water needed for extinguishing the fire had frozen inside the water pipes. The
firefighters had to let the fire burn until the substances fuelling the fire were exhausted.
Another common issue during natural disasters is the hampering of response
operations due to communication difficulties, phone-line unavailability due to damage or
system overload, power outages, damage to or obstruction by debris of transportation
lines, including roads, and slowed-down mobilisation of responders. This clearly also
affects response to a Natech accident. Much can be learned from the major fires that
involved hydrocarbon pipelines and three tanks (sulphur, asphalt and gasoline) at a
refinery in Sendai during the Tohoku earthquake and tsunami. The force of the tsunami
that washed into the refinery transported debris inland which blocked the access roads
to the installation. After the fire ignited, the emergency teams had no means of accessing
the site and it took days to effectively control the fire, during which time the blaze
engulfed the entire western plant section (Krausmann and Cruz, 2013).
EMERGENCY PLANNING AND RESPONSE FOR NATECH ACCIDENTS
TOWARDS AN ALL-HAZARDS APPROACH TO EMERGENC Y PREPAREDNESS AND RESPONSE, NEA No. 7308, © OECD 20 18 65
During natural disasters, Natech accidents that result in fires and explosions are likely
to propagate to neighbouring production units or even to neighbouring industrial
installations, in a process known as “domino effect”. For this reason, the vulnerability of
just one unit to a natural hazard impact may eventually cause damage to the entire
installation or even to more than one installation, e.g. in an industrial park. This cascading
behaviour is frequent during Natech events, as numerous accident reports indicate. For
instance, heavy rain and a subsequent flash flood caused a fire and several explosions at a
refinery in Morocco in 2002. Since the refinery’s surface-water and waste-water drainage
systems were not separated, the flood caused the waste waters which contained
hydrocarbon residues to be lifted out of the drainage system. The hydrocarbons floating
on the water surface ignited upon contact with hot refinery equipment and the fires
spread with the floodwaters (Cruz, Steinberg and Luna, 2001). Similarly, in Egypt in 1994
heavy rains caused flooding at a fuel depot during a thunderstorm. The storm triggered
fuel releases into the tank bunds which were, however, flooded and could not contain the
releases. The fuel stratified on the surface of the floodwaters and was ignited by a
lightning strike. The burning waters flowed into a village where they caused hundreds of
fatalities and injuries (Renni, Krausmann and Cozzani, 2010).
Another important lesson is that targeted training (including psychological aspects),
as well as sufficient and adequate equipment should be provided to emergency teams
who must respond to a Natech accident. In many Natech cases, it became necessary for
rescuers and firefighters to wear breathing apparatus, which were not always available in
sufficient numbers for all teams called to respond the emergency (Girgin, 2011). Similarly,
in case of past tsunamis, first responders intervening in the accident were not always
endowed with lifejackets to ensure their own safety. Additionally, depending on the type
of natural hazard that triggered the Natech accident, some response equipment might be
preferable over others that fulfil the same purpose. For instance, it was found that
responding to a Natech accident during flood conditions or after tsunamis is much
facilitated using aluminium boats rather than rubber boats which are less suited for
moving around in debris-laden water (Krausmann and Cruz, 2013). Moreover, emergency
responders are subjected to high levels of stress, in particular during major Natech
accidents. In addition to the risks to their own health due to hazardous material releases,
fires and explosions, duty shifts can last long and there would be uncertainty as to when
the response to the accident would be terminated. The psychological stress would be
exacerbated by worry for the health of relatives possibly caught in the natural disaster.
Numerous Natech accidents also highlighted the importance of a robust emergency
planning. In the aftermath of many Natech accidents, emergency procedures were found
lacking and were subsequently rewritten to account for natural events. In the case of the
Sendai refinery, the internal emergency procedure called for an inspection of the facility
after the earthquake to check for damage. Four operators died when caught in the
tsunami during this safety check (BARPI, 2013). Also the emergency response plan of the
refinery that suffered heavy damage during the Kocaeli earthquake was found to be
insufficient. Based on the lessons learnt during the management and co-ordination of the
response activities, a disaster management plan was prepared to improve the efficiency
in first response and the mitigation of consequences, including a revamping of fire and
oil-spill fighting capacities, which were increased drastically (Görgün, 2007).
Conclusions and recommendations
Awareness of Natech risks is increasing worldwide and there is a growing body of
research into the topic. Nonetheless, there is still a lack of Natech risk assessment
methodologies, and little guidance on Natech risk management for industry and
competent authorities. From an emergency management point of view, special planning
is required to account for the fact that major natural events can impact large areas,
affecting the population, the building stock, and industry as well as other infrastructures.
EMERGENCY PLANNING AND RESPONSE FOR NATECH ACCIDENTS
66 TOWARDS AN ALL-HAZARDS APPROACH TO EMERG ENCY PREPAREDNESS AND R ESPONSE, NEA No. 7308, © OECD 20 18
To ensure sufficient preparedness in industry and for emergency response to be effective,
the following points should be considered (Krausmann, Cruz and Salzano, 2017):
• On-site emergency plans for accidents involving hazardous materials should take
the risks from natural hazards into account. This includes consideration of
potential multiple and simultaneous releases from different parts of the
installation, as well as the possibility of secondary cascading accidents. Natech
scenarios used for emergency planning should reflect the unavailability of
instrumentation (e.g. sensors, alarms, indicators), safety-relevant devices and
equipment (e.g. safety valves, firefighting equipment, flare stacks), personnel, and
plant-internal and external lifelines during the natural event. Moreover, it is
recommended that on-site emergency plans assume that off-site response
resources are unavailable. Plans should also consider loss of communication with
external emergency responders, as well as panic and flight behaviour of plant
personnel which can result in a failure to take protective actions at plant level
(e.g. blow-down of pressurised hazardous processes, safe plant shutdown, etc.)
(Steinberg and Cruz, 2004). Mechanisms need to be identified to deal with the
potential lack of personnel trained to handle emergencies.
• Off-site emergency response plans for hazardous industry in natural hazard-
prone areas need to consider the impact of hazardous materials releases caused
by natural events on the population and on rescue operations. These plans
should prepare for emergency evacuation of the population in case of an
accident, but consider that roads might be inaccessible, e.g. in case of floods or
tsunamis. First responders should pay attention to possibly violent reactions of
released chemicals with floodwaters or rain which can create secondary toxic or
flammable compounds from less harmful precursor chemical compounds
(Cozzani et al., 2010).
• The vulnerability of emergency response resources to natural events and
hazardous materials releases should be assessed. This includes careful
consideration of conflicting emergency management objectives like carrying out
search and rescue operations while at the same time having to evacuate because
of a hazardous materials threat. Law enforcement officers who help in the
evacuation and who secure evacuation zones are also at risk of exposure to
hazardous materials and should receive proper training to better protect
themselves and the population (Girgin, 2011).
• Medical services should be involved in the preparation of the external emergency
plan. If doctors and hospitals are not prepared for a major Natech scenario, they
are likely to be overwhelmed by the onrush of natural disaster victims as well as of
people who have suffered toxic effects or burns. They should be informed about
the risks from neighbouring hazardous installations and natural events by
competent authorities and they should ensure that sufficient and adequate
medication to treat victims of hazardous materials releases is in stock.
• Emergency response plans, at both installation and community level, should be
periodically reviewed and tested to make certain they consider the consequences
of natural hazard impacts. This should include an assessment of the validity of
assumptions made on the expected natural hazard frequency and severity which
could be affected by e.g. improvements in hazard modelling or climate change. In
this context, the possibility that natural hazard loading might exceed the
maximum design specifications should also be considered.
EMERGENCY PLANNING AND RESPONSE FOR NATECH ACCIDENTS
TOWARDS AN ALL-HAZARDS APPROACH TO EMERGENC Y PREPAREDNESS AND RESPONSE, NEA No. 7308, © OECD 20 18 67
References
BARPI (2013), Overview of the Industrial Accidents Caused by the Great Tohoku Earthquake and
Tsunami, Ministry of Ecology, Sustainable Development and Energy, Paris.
CalARP (2014), “Guidance for California Accidental Release Prevention (CalARP) Program:
Seismic Assessments”, CalARP Program Seismic Guidance Committee,
www.caloes.ca.gov/FireRescueSite/Documents/SGD%20LEPC%20I%20Approved%2003
%2012%202014.pdf.
Cozzani, V. et al. (2010), “Industrial accidents triggered by flood events: analysis of past
accidents”, Journal of Hazardous Materials, Vol. 175, Issues 1-3, pp. 501-509.
Cruz, A.M. and N. Okada (2008), “Methodology for preliminary assessment of Natech risk
in urban areas”, Natural Hazards, Vol. 46, Issue 2, pp. 199-220.
Cruz, A.M., L.J. Steinberg and R. Luna (2001), “Identifying hurricane-induced hazardous
materials release scenarios in a petroleum refinery”, Natural Hazards Review, Vol. 2,
Issue 4, p. 203.
Girgin, S. (2011), “The Natech events during the 17 August 1999 Kocaeli earthquake:
aftermath and lessons learned”, Natural Hazards and Earth System Sciences, Vol. 11,
Issue 4, pp. 1129-1140.
Godoy, L.A. (2007), “Performance of storage tanks in oil facilities damaged by Hurricanes
Katrina and Rita”, Journal of Performance of Constructed Facilities, Vol. 21, Issue 6, p. 441.
Görgün, M. (2007), “Major industrial accidents happened in Körfez”, Occupational Health
and Safety Congress, Adana, Turkey, 20-21 April 2007 (in Turkish).
Hudec, P. and O. Lukš (2004), “Flood at Spolana a.s. in August 2002”, Loss Prevention Bulletin,
Vol. 180, Issue 1, p. 36, UK Institution of Chemical Engineers.
Krausmann, E., A.M. Cruz and E. Salzano (2017), Natech Risk Assessment and Management –
Reducing the Risk of Natural-hazard Impact on Hazardous Installations, Elsevier,
Amsterdam.
Krausmann, E. and A.M. Cruz (2013), “Impact of the 11 March 2011, Great East Japan
Earthquake and tsunami on the chemical industry”, Natural Hazards, Vol. 67, Issue 2,
pp. 811-828.
Krausmann, E. and D. Baranzini (2012), “Natech risk reduction in the European Union”,
Journal of Risk Research, Vol. 15, Issue 8, pp. 1027-1047.
Krausmann, E., A.M. Cruz and B. Affeltranger (2011), “The impact of the 12 May 2008
Wenchuan earthquake on industrial facilities”, Journal of Loss Prevention in the Process
Industries, Vol. 23, Issue 2, pp. 242-248.
OECD (2015), “Addendum No. 2 to the OECD Guiding Principles for Chemical Accident
Prevention, Preparedness and Response (2nd Ed.) to Address Natural Hazards
Triggering Technological Accidents (Natechs)”, OECD Series on Chemical Accidents
No. 27, ENV/JM/MONO(2015)1.
Planseisme (2012), ICPE « à risque spécial » (in French), Ministère du Développement
Durable, www.planseisme.fr/ICPE-a-risque-special-1476b.
Renni, E., E. Krausmann and V. Cozzani (2010), “Industrial accidents triggered by
lightning”, Journal of hazardous materials, Vol. 184, Issues 1-3, pp. 42-48.
Steinberg, L.J. and A.M. Cruz (2004), “When natural and technological disasters collide:
Lessons from the Turkey earthquake of August 17, 1999”, Natural Hazards Review,
Vol. 5, Issue 3, p. 121.
EMERGENCY PLANNING AND RESPONSE FOR NATECH ACCIDENTS
68 TOWARDS AN ALL-HAZARDS APPROACH TO EMERG ENCY PREPAREDNESS AND R ESPONSE, NEA No. 7308, © OECD 20 18
TRAS 310 (2012a), “Technische Regel für Anlagensicherheit: Vorkehrungen und
Maßnahmen wegen der Gefahrenquellen Niederschläge und Hochwasser” (in
German), Bundesanzeiger, Supplement 32a, German Federal Cabinet, BMU, non-official
version, www.kas-bmu.de/publikationen/tras/TRAS310_nicht_offizielle_Version.pdf.
TRAS 310 (2012b), “Technical Rule on Installation Safety: Precautions and Measures due to
Precipitation and Floods”, German Federal Cabinet, BMU, non-official short version,
www.kas-bmu.de/publikationen/tras/TRAS_310_GB_shortversion.pdf.
US EPA (2006), “Murphy Oil Spill Fact Sheet”, K1-C-020106-FS-Murphy, www.columbia.edu
/itc/journalism/cases/katrina/Federal%20Government/Environmental%20Protection%2
0Agency/Murphy%20Oil%20Spill%20Fact%20Sheet%20Feb%202006.pdf.
